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June 5, 2025

Modernising UK Cyber Regulation: Implications of the Cyber Security and Resilience Bill

The UK Government’s upcoming Cyber Security and Resilience Bill (CSRB) will modernise the UK’s 2018 NIS regime, extend regulatory duties to managed service providers and data‑centre operators, and tighten supply‑chain oversight. This blog explains the policy intent and outlines practical implications for service providers and enterprise security leaders.
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Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
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05
Jun 2025

The need for security and continued cyber resilience

The UK government has made national security a key priority, and the new Cyber Security and Resilience Bill (CSRB) is a direct reflection of that focus. In introducing the Bill, Secretary of State for Science, Innovation and Technology, Peter Kyle, recognised that the UK is “desperately exposed” to cyber threats—from criminal groups to hostile nation-states that are increasingly targeting the UK's digital systems and critical infrastructure[1].

Context and timeline for the new legislation

First announced during the King’s Speech of July 2024, and elaborated in a Department for Science, Innovation and Technology (DSIT) policy statement published in April 2025, the CSRB is expected to be introduced in Parliament during the 2025-26 legislative session.

For now, organisations in the UK remain subject to the 2018 Network and Information Systems (NIS) Regulations – an EU-derived law which was drafted before today’s increasing digitisation of critical services, rise in cloud adoption and emergence of AI-powered threats.

Why modernisation is critical

Without modernisation, the Government believes UK’s infrastructure and economy risks falling behind international peers. The EU, which revised its cybersecurity regulation under the NIS2 Directive, already imposes stricter requirements on a broader set of sectors.

The urgency of the Bill is also underscored by recent high-impact incidents, including the Synnovis attack which targeted the National Health Service (NHS) suppliers and disrupted thousands of patient appointments and procedures[2]. The Government has argued that such events highlight a systemic failure to keep pace with a rapidly evolving threat landscape[3].

What the Bill aims to achieve

This Bill represents a decisive shift. According to the Government, it will modernise and future‑proof the UK’s cyber laws, extending oversight to areas where risk has grown but regulation has not kept pace[4]. While the legislation builds on previous consultations and draws lessons from international frameworks like the EU’s NIS2 directive, it also aims to tailor solutions to the UK’s unique threat environment.

Importantly, the Government is framing cybersecurity not as a barrier to growth, but as a foundation for it. The policy statement emphasises that strong digital resilience will create the stability businesses need to thrive, innovate, and invest[5]. Therefore, the goals of the Bill will not only be to enhance security but also act as an enabler to innovation and economic growth.

Recognition that AI changes cyber threats

The CSRB policy statement recognises that AI is fundamentally reshaping the threat landscape, with adversaries now leveraging AI and commercial cyber tools to exploit vulnerabilities in critical infrastructure and supply chains. Indeed, the NCSC has recently assessed that AI will almost certainly lead to “an increase in the frequency and intensity of cyber threats”[6]. Accordingly, the policy statement insists that the UK’s regulatory framework “must keep pace and provide flexibility to respond to future threats as and when they emerge”[7].

To address the threat, the Bill signals new obligations for MSPs and data centres, timely incident reporting and dynamic guidance that can be refreshed without fresh primary legislation, making it essential for firms to follow best practices.

What might change in day-to-day practice?

New organisations in scope of regulation

Under the existing Network and Information Systems (NIS) Regulations[8], the UK already supervises operators in five critical sectors—energy, transport, drinking water, health (Operators of Essential Services, OES) and digital infrastructure (Relevant Digital Service Providers, RDSPs).

The Cyber Security and Resilience Bill retains this foundation and adds Managed Service Providers (MSPs) and data centres to the scope of regulation to “better recognise the increasing reliance on digital services and the vulnerabilities posed by supply chains”[9]. It also grants the Secretary of State for Science, Innovation and Technology the power to add new sectors or sub‑sectors via secondary legislation, following consultation with Parliament and industry.

Managed service providers (MSPs)

MSPs occupy a central position within the UK’s enterprise information‑technology infrastructure. Because they remotely run or monitor clients’ systems, networks and data, they hold privileged, often continuous access to multiple environments. This foothold makes them an attractive target for malicious actors.

The Bill aims to bring MSPs in scope of regulation by making them subject to the same duties as those placed on firms that provide digital services under the 2018 NIS Regulations. By doing so, the Bill seeks to raise baseline security across thousands of customer environments and to provide regulators with better visibility of supply‑chain risk.

The proposed definition for MSPs is a service which:

  1. Is provided to another organisation
  2. Relies on the use of network and information systems to deliver the service
  3. Relates to ongoing management support, active administration and/or monitoring of AI systems, IT infrastructure, applications, and/or IT networks, including for the purpose of activities relating to cyber security.
  4. Involves a network connection and/or access to the customer’s network and information systems.

Data centres

Building on the September 2024 designation of data centres as critical national infrastructure, the CSRB will fold data infrastructure into the NIS-style regime by naming it an “relevant sector" and data centres as “essential service”[10].

About 182 colocation facilities run by 64 operators will therefore come under statutory duties to notify the regulator, maintain proportionate CAF-aligned controls and report significant incidents, regardless of who owns them or what workloads they host.

New requirements for regulated organisations

Incident reporting processes

There could be stricter timelines or broader definitions of what counts as a reportable incident. This might nudge organisations to formalise detection, triage, and escalation procedures.

The Government is proposing to introduce a new two-stage incident reporting process. This would include an initial notification which would be submitted within 24 hours of becoming aware of a significant incident, followed by a full incident report which should be submitted within 72 hours of the same.

Supply chain assurance requirements

Supply chains for the UK's most critical services are becoming increasingly complex and present new and serious vulnerabilities for cyber-attacks. The recent Synnovis ransomware attacks on the NHS[11] exemplify the danger posed by attacks against the supply chains of important services and organisations. This is concerning when reflecting on the latest Cyber Security Breaches survey conducted by DSIT, which highlights that fewer than 25% of large businesses review their supply chain risks[12].

Despite these risks, the UK’s legacy cybersecurity regulatory regime does not explicitly cover supply chain risk management. The UK instead relies on supporting and non-statutory guidance to close this gap, such as the NCSC’s Cyber Assessment Framework (CAF)[13].

The CSRB policy statement acts on this regulatory shortcoming and recognises that “a single supplier’s disruption can have far-reaching impacts on the delivery of essential or digital services”[14].

To address this, the Bill would make in-scope organisations (OES and RDPS) directly accountable for the cybersecurity of their supply chains. Secondary legislation would spell out these duties in detail, ensuring that OES and RDSPs systematically assess and mitigate third-party cyber risks.

Updated and strengthened security requirements

By placing the CAF into a firmer footing and backing it with a statutory Code of Practice, the Government is setting clearer expectations about government expectations on technical standards and methods organisations will need to follow to prove their resilience.

How Darktrace can help support affected organizations

Demonstrate resilience

Darktrace’s Self-Learning AITM continuously monitors your digital estate across cloud, network, OT, email, and endpoint to detect, investigate, and autonomously respond to emerging threats in real time. This persistent visibility and defense posture helps organizations demonstrate cyber resilience to regulators with confidence.

Streamline incident reporting and compliance

Darktrace surfaces clear alerts and automated investigation reports, complete with timeline views and root cause analysis. These insights reduce the time and complexity of regulatory incident reporting and support internal compliance workflows with auditable, AI-generated evidence.

Improve supply chain visibility

With full visibility across connected systems and third-party activity, Darktrace detects early indicators of lateral movement, account compromise, and unusual behavior stemming from vendor or partner access, reducing the risk of supply chain-originated cyber-attacks.

Ensure MSPs can meet new standards

For managed service providers, Darktrace offers native multi-tenant support and autonomous threat response that can be embedded directly into customer environments. This ensures consistent, scalable security standards across clients—helping MSPs address increasing regulatory obligations.

[related-resource]

References

[1] https://www.theguardian.com/uk-news/article/2024/jul/29/uk-desperately-exposed-to-cyber-threats-and-pandemics-says-minister

[2] https://www.england.nhs.uk/2024/06/synnovis-cyber-attack-statement-from-nhs-england/

[3] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

[4] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

[5] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

[6] https://www.ncsc.gov.uk/report/impact-ai-cyber-threat-now-2027

[7] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

[8] https://www.gov.uk/government/collections/nis-directive-and-nis-regulations-2018

[9] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

[10] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

[11] https://www.england.nhs.uk/2024/06/synnovis-cyber-attack-statement-from-nhs-england/

[12] https://www.gov.uk/government/statistics/cyber-security-breaches-survey-2025/cyber-security-breaches-survey-2025

[13] https://www.ncsc.gov.uk/collection/cyber-assessment-framework

[14] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

See Darktrace's Products & Solutions

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Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
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September 4, 2026

Darktrace Advances Incident Investigation and AI-Agent Security with OpenAI Daybreak Models

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Earlier this year, Darktrace joined OpenAI’s Daybreak Defense Network to explore how their cyber capabilities can be integrated within Darktrace products and services to transform how security teams move from signal to action.

At the heart of this work is Darktrace's behavioral understanding of customer environments and identification of complex security incidents, combined with OpenAI models that can add context to help explain why an incident matters and its potential impact on the business. By bringing these capabilities into defensive workflows security teams already use, the goal is to give defenders not just greater visibility, but the context and guidance they need to act with confidence.

Since joining the program, we've been working with OpenAI to explore how these capabilities can address specific security challenges for defenders.

The problem we're solving

Attackers continue to change how they operate, including by using AI to increase the speed and scale of some techniques. Security teams are already managing a large volume of alerts, and the question isn't just what's happening, but how it could affect the organization. Even when an incident is fully investigated and correlated, technical severity alone doesn't tell a security team how much it actually matters to the business. That same challenge extends to internal AI adoption. As organizations adopt more AI systems and agents, security teams need visibility into their behavior, access and activity, along with the broader business context needed to identify and investigate potential risk.

Darktrace's Adaptive AI™ builds a detailed, organization-specific picture of what's normal for each environment, and uses that picture to investigate threats and identify complex security activity across domains. OpenAI's models can build on Darktrace's correlated, technically prioritized incidents by adding context that can help defenders understand what may be at stake.

What we're building

Our work is focused on two areas: supporting security investigation and response, and helping defenders identify risky behavior across enterprise AI systems and agents.

The first aligns Darktrace's behavioral understanding with OpenAI models to support  security investigation and prioritization. Darktrace's Adaptive AI continuously learns the unique patterns of normal behavior within each customer it protects, creating a deep, organization-specific understanding of its digital estate. When unusual activity emerges, OpenAI's models can draw on that context to help analysts investigate the incident, understand its significance and assess potential business consequences — reducing the need to manually assemble context from fragmented signals.

Second, we are exploring how these capabilities can support AI-agent and runtime security through Darktrace / SECURE AI™. OpenAI’s Daybreak models can build on the detections and visibility Darktrace / SECURE AI provides, connecting signals across a customer's environment and help defenders identify potentially risky behavior involving AI systems and agents. Activity that might appear isolated can instead be connected with related signals, helping defenders investigate the broader context and determine appropriate remediation.

Darktrace brings deep cybersecurity expertise, an evolving understanding of each customer's environment, and AI-driven identification of threats across the digital estate. Through the Daybreak Defense Network, Darktrace is exploring how OpenAI models can augment those capabilities in defensive security workflows — supporting incident investigation and response and improving visibility into AI-agent and runtime risk.

These capabilities are still in development, and we're excited to continue building on this work.

To learn more about how Darktrace continues to innovate to meet today's most pressing security challenges, register for our upcoming launch broadcast here.

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About the author
Dr. Tim Bazalgette
Chief AI Officer, Darktrace

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September 4, 2026

Botnet Behind the Camera: Mirai Katana Activity on a Video Recording Device

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Key takeaways

  • Darktrace identified a camera device infected with the Mirai/Katana botnet in a sports-sector customer environment, showing how exposed IoT devices can become active participants in wider attack chains.
  • The compromise involved suspicious Wget behavior, file downloads from rare external IPs, unusual incoming HTTP connections to video recorder management interfaces, and large outbound data transfers to infrastructure associated with botnet activity.
  • The incident highlights the importance of extending visibility and response beyond traditional endpoints, as unmanaged or overlooked connected devices can be exploited for command-and-control, malware delivery, and data exfiltration.

Mirai and the Katana variant

Mirai is a botnet that first emerged in August 2016 and is well known for launching large-scale distributed-denial-of-service (DDoS) attacks, typically targeting exposed Internet of Things (IoT) devices. It identifies vulnerable IoT devices ,often by abusing default credentials or exposed services, and recruiting them into a remotely controlled botnet that can be used in DDoS campaigns [1].

Katana, one of the many variants that arose after Mirai’s source code was released publicly, was first observed in late 2020 and has been seen using more advanced capabilities, including custom command-and-control (C2), persistence mechanisms, and DDoS functionality [2].

In March 2026, research from the Nokia Deepfield Emergency Response Team (ERT) identified Katana as a Mirai-derived DDoS botnet targeting Android-based TV set-top boxes through exposed Android Debug Bridge (ADB) access.  Observed capabilities included custom C2, runtime domain rotation, multiple DDoS methods, and an on-device compiled kernel rootkit used for persistence and stealth [3].

Darktrace’s detection of Mirai Botnet activity on a camera device

In early 2026, Darktrace identified a Network/Digital Video Recorder (NVR/DVR) on the network of a sports-sector customer that had been infected with the Mirai Katana botnet and subsequently used to exfiltrate data from the customer’s environment. Seemingly related follow-up activity was observed on the same device several months later.

In both instances, the Darktrace Security Operations Centre (SOC) alerted the customer as part of the Managed Threat Detection (MTD) service. However, as Darktrace’s Autonomous Response capability was not fully enabled on the affected device, Darktrace was unable to proactively block the suspicious activity or prevent the compromise from continuing and recurring.

The initial compromise appears to have occurred when the affected device was seen using Wget to download Linux-based Executable and Linkable Format (ELF) files from a rare external IP, 195.177.94[.]105, which had not previously been observed in the customer’s network. Further analysis downloaded file hashes identified files related to the Mirai botnet.

Figure 1: Darktrace’s Real-Time AI Analyst investigation into the unusual outbound connection where the ELF files were downloaded.

Within a few hours, Darktrace detected the device uploading close to 3GB of data to another external IP, 50.7.49[.]4:3017 (ASN AS30058 FDCSERVERS), suggesting that the activity was likely routed via a virtual private server (VPS) hosted by FDC Servers [2]. Attackers often abuse VPS infrastructure from legitimate cloud providers to blend in with legitimate traffic and evade IP reputation and geolocation-based detections.

Figure 2:  Darktrace’s detection of the unusual data upload activity by the affected camera device.

Darktrace continued to observe similar data transfers to multiple rare endpoints  including 171.225.223[.]53, 95.161.128[.]62, 61.7.209[.]88, 95.161.128[.]62, which have been linked to Mirai by open-source intelligence (OSINT).

Figure 3: Darktrace’s detection of spikes in unusual external data transfer activity from the camera device.

Exploitation continued

Several months later, Darktrace identified the same exfiltration pattern on the device again, this time with stronger indications of associations with Mirai Katana botnet infection.

The device received incoming HTTP connections from 129.121.114[.]124, an external IP known to be associated with the Katana botnet IP [3]. The connections targeted the ‘/dvr/cmd’ path using the root username and user agent Mozilla/5.0 (Windows NT 10.0; Win64; x64) AppleWebKit/537.36 (KHTML, like Gecko) Chrome/42.0.2311.135 Safari/537.36 Edge/12.246.

The ‘/dvr/cmd’ path appears to be associated with the affected device’s web management functionality. This API endpoint has historically been targeted by Mirai and other IoT botnets through the exploitation of critical command injection vulnerabilities and automated botnet exploitation [4].

Figure 4: Darktrace’s  detection of HTTP connectivity from the external IP associated with Mirai Katana Botnet.

A few days later, Darktrace observed the Wget utility being used to download ELF files, including “/lil”,  from the IP 129.121.114[.]124. OSINT reporting has since associated this IP address with the Mirai Katana botnet. Notably, the IP observed earlier in the year, 195.177.94[.]105, had also hosted a file named “lil”, indicating a link between the observed activity.

Over the following days, the device received a sudden spike in connections from multiple rare external endpoints, suggesting a possible successful brute force attack. Darktrace also observed the device exfiltrating just under 4GB of data to another Mirai-associated IP address,  66.92.198[.]194, over ports 3344, 954922, and 80. Finally, the device was seen uploading data to the Mirai botnet IP 5.175.249[.]53 over port138 and exhibited an increase in UDP connections to 34.18.28[.]10 over port 9068.

Following both file download events, Darktrace identified spikes in external data transfers and connection attempts to rare destinations. While Darktrace’s Threat Research team could not confirm with high confidence that this to activity was directly associated with Mirai, it may indicate that Mirai Katana includes data exfiltration functionality.

Darktrace’s threat researchers also identified an internet-facing NTP server belonging to a separate customer receiving incoming connection attempts from the same initially observed IP, 195.177.94[.]105,over the port 123. This suggests that Mirai Katana may not exclusively target IoT devices.

Conclusion

This case demonstrates how threat actors can exploit overlooked IoT and OT devices to support broader malicious objectives. Here, a camera device infected with a botnet was used to exfiltrate data from the customer's environment, showing how peripheral assets can become active participants in an attack chain.

This case also reinforces a challenge many organizations face today: extending security visibility beyond traditional endpoints and servers. Cameras, sensors, and other connected devices often operate with limited monitoring and may fall outside established security processes, despite maintaining network connectivity and access to potentially sensitive environments. This is particularly relevant in the sports sector, where growing reliance on connected cameras, smart stadium technologies, and other IoT devices continues to expand the attack surface, as highlighted in Darktrace's Sports Sector Threat Report.

As botnets like Kata and Mirai continue to evolve, defenders need visibility across unmanaged IoT and edge devices, as well as security solutions that can recognize subtle deviations in device behavior that may indicate an emerging compromise.

Credit to Parvatha Ananthakannan (Cyber Analyst), Signe Zaharka (Principal Analyst)

Edited by Ryan Traill (Content Manager)

Appendices

Darktrace Model Detections

·      Anomalous File / EXE from Rare External Location

·      Anomalous File / Multiple EXE from Rare External Locations

·      Device / Initial Attack Chain Activity

·      Unusual Activity / Unusual External Data to New Endpoint

·      Anomalous Connection / Data Sent to Rare Domain

·      Unusual Activity / Enhanced Unusual External Data Transfer

·      Anomalous Connection / Uncommon 1 GiB Outbound

·      Device / Significant UDP Increase

·      Anomalous Connection / Low and Slow Exfiltration to IP

·      Compromise / Large Number of Suspicious Failed Connections

·      Compromise / Large Number of Suspicious Successful Connections

·      Unusual Activity / Unusual External Activity

·      Compliance / SSH to Rare External Destination

·      Unusual Activity / Unusual DNS

·      Device / External Network Scan

·      Device / Suspicious DNS Activity

·      Device / Large Number of Model Alerts

List of Indicators of Compromise (IoCs)

Indicator of Compromise Type Description
195.177.94[.]105 IP C2 endpoint
50.7.49[.]4:30171 IP Possible C2 endpoint
129.121.114[.]124 IP C2 endpoint
hxxp://195.177.94[.]105/n3 URL Likely C2 endpoint
hxxp://195.177.94[.]105/n2 URL Likely C2 endpoint
hxxp://129.121.114[.]124/lil URL Likely C2 endpoint
hxxp://129.121.114[.]124/HHn URL Possible C2 endpoint
hxxp://129.121.114[.]124/JFc URL Possible C2 endpoint
hxxp://129.121.114[.]124/jum URL Likely C2 endpoint
hxxp://129.121.114[.]124/OaSf URL Likely C2 endpoint
hxxp://129.121.114[.]124/OPWg URL Possible C2 endpoint
hxxp://129.121.114[.]124/vHwK URL Possible C2 endpoint
hxxp://129.121.114[.]124/VLv URL Possible C2 endpoint
hxxp://129.121.114[.]124/WbJ URL Possible C2 endpoint
hxxp://129.121.114[.]124/zkR URL Possible C2 endpoint
Ab17883ae4c3bc6afa18c439166eeeb4b03186e3093d984e3a95f573e0fcb7d8 SHA-256 Mirai payload
3d587e809dac49d34a3f717e072fd0aebe5e71db63333e45c81577d6b4266f87 SHA-256 Mirai payload
Bf6e81733a7e209d3dce80d15bf3c5d300752d961fae6b45d90c9bbe7f8c89a2 SHA-256 Possible payload
f25488303813ab1ec0eaa71562938601aac185e8aaf93adb84522557f7cf4dd6 SHA-256 Possible payload
0cb4ff6b71f4423184bfa35c34e9090297637208b0e30205d4b224e56abde2ef SHA-256 Possible payload
19c24cbeaf06b2e7697083f33a85521a9315105c784691bde7420fde4cc69410 SHA-256 Likely Mirai payload
1e74f734fff8df91f4f7172d0de10c421eca78aeb800e8a48e16bc5dbde5d20e SHA-256 Possible payload
6e71f7763d1f29d5712106ebb122e281c32787540aa2342b0fe5351d585d18d7 SHA-256 Possible payload
71f4ff7cdb6d6a7d2673c543c5d2535093afbd707b20a5b9ddf735466c1105c1 SHA-256 Possible payload
76db7ee73ebf15e48a3cb24a074d92248671ef2c6ed3bc3e708377341fb7674d SHA-256 Possible payload
da87a65f7beb438e61f0b61964fed8aa305a380f569042f84c55eca8fa7929b8 SHA-256 Possible payload
e15809eb6ba66477175270d62cfa53e4bf278595f69938708c81c4bc457930fe SHA-256 Mirai payload

MITRE ATT&CK Mapping

Tactic Technique ID Technique / Sub-technique
Initial Access T1659 Content Injection
T1189 Drive-by Compromise
Exfiltration T1041 Exfiltration Over C2 Channel
T1048.003 Exfiltration Over Unencrypted Non-C2 Protocol
Command and Control T1105 Ingress Tool Transfer
T1095 Non-Application Layer Protocol
T1571 Non-Standard Port
Reconnaissance T1595.001 Scanning IP Blocks
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About the author
Parvatha Ananthakannan
Cyber Analyst
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